GR 201478; (August, 2017) (Digest)
G.R. No. 201478 , August 23, 2017
People of the Philippines, Plaintiff-Appellee, vs. Parok Lumudag y Racman @ Akmad, Accused-Appellant.
FACTS
The accused-appellant, Parok Lumudag, was charged with the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution’s narrative, as affirmed by the Regional Trial Court and the Court of Appeals, detailed a buy-bust operation on September 6, 2008, in Quiapo, Manila. A police team, with PO2 Richard Donato as the poseur-buyer, allegedly transacted with Lumudag, where the marked money was exchanged for a plastic sachet later confirmed to contain 0.016 gram of shabu. The defense presented a starkly different version, claiming Lumudag was merely disposing of garbage when he accidentally splashed water on men on a motorcycle, leading to his arrest, mauling, and extortion at the police station.
ISSUE
The core issue is whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in establishing the integrity and identity of the seized drug as the corpus delicti of the crime.
RULING
The Supreme Court reversed the lower courts’ decisions and acquitted Lumudag. The legal logic centered on the prosecution’s failure to establish an unbroken chain of custody over the seized drug, which is crucial in proving the identity of the corpus delicti beyond reasonable doubt. The Court emphasized that in drug cases, the State must account for each link in the chain: from seizure, to marking, to turnover for laboratory examination, to presentation in court. Any gap or irregularity raises doubt about the evidence’s integrity.
Here, the Court found a critical break in this chain. The prosecution did not present the testimony of the forensic chemist, PSI Erickson Calabocal, who examined the drug. His testimony was essential to establish that the specimen tested was the very item seized from Lumudag and presented in court. Without this, the prosecution failed to prove that the item offered as evidence was the same one allegedly sold. The mere stipulation by the defense regarding the chemist’s report was insufficient to cure this fatal omission, as it did not affirm the report’s contents or the integrity of the handling process. Consequently, the identity of the prohibited drug was not established with moral certainty. The presumption of innocence prevailed, and any doubt was resolved in favor of the accused, mandating acquittal.